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OWENS v. COMMISSIONER

Docket No. 17697-86.

53 T.C.M. 645 (1987)

T.C. Memo. 1987-207

Bob R. Owens and Judy M. Owens v. Commissioner.

United States Tax Court.

Filed April 23, 1987.

Attorney(s) appearing for the Case

Philip R. Linsley, 15250 Ventura Blvd., Sherman Oaks, Calif., for the petitioners. Gordon Dickey and Monica S. Melgarejo, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

Respondent's Motion to Dismiss for Lack of Jurisdiction, and petitioners' Motion to Dismiss for Lack of Jurisdiction were assigned to Special Trial Judge Peter J. Panuthos for hearing and consideration.1 After a review of the record, we agree with and adopt his opinion which is set forth below.

Opinion of the Special Trial Judge

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